Requirement of an order levying interest u/s 216.

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..... ssessment order. The order under section 216 is specifically appealable vide sub-clause(m) of Section 216. It is, therefore, obvious that the Income-tax Officer's order directing an assessee to pay interest under section 216 should be a speaking order, giving his reasons for coming to the conclusion that such interest is leviable to enable the appellate authority to appreciate the issues involved. .....

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..... and proper conclusions have to be reached after hearing him on the circumstances under which he committed such defaults. It is only on such a finding that under-estimation/wrongful deferment has been made by an assessee that the Income-tax Officer can levy interest under section 216. Since the finding rests on the Income-tax Officer's appreciation of the facts, the reasons supporting his conclusio .....

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